ANTI MONEY LAUNDERING (AML)
COUNTERING FINANCING OF TERRORISM (CFT)
Switzerland, as a FATF member, follows the regulation of money laundering which is based on
two pillars. Firstly, money laundering is a criminal offence punishable by law (Art. 305bis of the Swiss Criminal Code). Secondly, the Federal Act on Combating Money Laundering
and Terrorist Financing in the Financial Sector (Anti-Money Laundering Act, AMLA) requires financial intermediaries to comply with due diligence and disclosure requirements with
respect to client transactions.
WE FOLLOW REQUIREMENTS FOR FINANCIAL INTERMEDIARIES:
As all financial intermediaries - whether supervised by FINMA or monitored by an SRO - must comply with a range of due diligence and disclosure requirements in relation to combating money laundering,
we assiduously follow the procedures stated below:
• We rigorously verify the identity of the contracting partner and identify the beneficial owner of the assets brought in. A thorough background check is performed on the related parties in light of various guidelines, sanctions lists and regulatory details.
• If a business relationship or transaction appears unusual, or if there are indications that the funds stem from criminal activity, or serve to finance terrorism, we strictly clarify the financial background and purpose of the business relationship or transaction.
• Business relationships and transactions with heightened risk, such as business relationships with clients in high-risk countries or with politically exposed persons (PEPs) are first of all not accepted out rightly but are recorded and clarified in greater detail.
• We adopt and implement the necessary organizational measures to prevent money laundering and financing of terrorism, including issuing internal directives, training and awareness for staff and performing inspections on a regular basis. The same rigor is applied to our branches. We do not strive to work with any Shell companies.
• We are always diligent in case of any suspicion of money laundering with regards to a business relationship, and submit a report to the Money Laundering Reporting Office (MROS) of the Federal Department of Justice and Police.
ANTI-MONEY LAUNDERING POLICY STATEMENT
• We, as an SRO (Self-Regulated Organization) have adopted and enforced the provisions enunciated by FINMA in our Anti-Money Laundering Compliance Manual to prevent and detect money laundering, terrorist financing and other illegal activities.
• If our personnel and/or premises are inadvertently used for money laundering or other illegal activities, we can be subject to potentially serious civil and/ or criminal penalties. Therefore, it is imperative that every member, officer, director, partner and employee (each, an “Employee”) is familiar with and complies with the policies and procedures set forth within Compliance Manual.
• This Compliance Statement is designed to assist all clients in adhering to our policies and procedures, which, if followed diligently, are designed to protect themselves, us, its Employees, its facilities and its activities from money laundering or other illegal activities.
• To ensure that our policies and procedures are adhered to, we have designated an Anti- Money Laundering Compliance Officer (the “Compliance Officer”). The Compliance Officer is responsible for establishing and conducting Employee training and awareness programs to ensure that all Employees are aware of the applicable and appropriate anti- money laundering laws and regulations, EST CAPITAL anti- money laundering policies and their responsibilities with respect to these policies.